The Effectiveness of the Community Reinvestment Act, Darryl E. Getter, Specialist in Financial Economics, January 7, 2015.
“This report informs the congressional debate concerning the CRA’s effectiveness in incentivizing bank lending and investment activity to LMI borrowers. After a discussion of the CRA’s origins, it presents the CRA’s examination process and bank activities that are eligible for consideration of CRA credits. Next, it discusses the difficulty of determining the CRA’s influence on bank behavior. For example, it could be argued that, by encouraging lending in LMI neighborhoods, the CRA may also encourage the issuance of higher-risk loans. Regulators, however, generally do not award CRA credits for payday and most subprime (nontraditional mortgage) loans, even if these loans originated in LMI areas. This regulatory practice suggests the CRA has little or no
influence on higher-risk lending. In addition, banks face a variety of financial incentives (e.g., capital requirements, the current interest rate environment, consumer credit demand, and consumer credit history) that influence how much (or how little) they lend to LMI borrowers. Because financial and CRA incentives concurrently exist, it is difficult to separate how much influence should be attributed solely to the CRA. Furthermore, compliance with CRA does not require adherence to lending quotas or benchmarks. In the absence of benchmarks, determining the extent to which CRA incentives have influenced LMI credit availability relative to other factors is not straightforward.”
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